A Healthier Future: analysis of consultation responses

6. Food labelling (Q5)

6.1 The consultation paper explained how labelling works alongside other aspects of the food environment (information, advice, reformulation, etc.) to make it easier for people to make more informed – and healthier – choices. It also described the UK-wide voluntary Front of Pack ( FoP) colour coded nutrition labelling scheme (introduced in 2013) which is used on about two-thirds of all pre-packed food and drink products in the UK. Finally, the paper set out the Scottish Government’s intention to explore how current labelling arrangements could be strengthened.

6.2 The consultation asked whether respondents thought current labelling arrangements could be strengthened.

Question 5: Do you think current labelling arrangements could be strengthened? Please explain your answer.

6.3 A total of 286 respondents (137 organisations and 149 individuals) provided comments. As no responses were received from those in the advertising industry, the private sector response for this question comes from respondents in the food and drink industry only.

Views of those in the food and drink industry

6.4 Respondents from the food and drink industry were generally content with current labelling arrangements and did not think these needed to be changed or strengthened. These respondents thought current arrangements were working well and were ‘popular and effective’ with consumers. They highlighted the industry’s compliance with current EU and UK-wide labelling regulations and the participation of many (though not all) businesses in voluntary mechanisms such as front of pack labelling. These respondents thought that additions or changes to current arrangements would be confusing for consumers, and they asked for there to be a full review of the efficacy of the current approach before any new responsibilities were imposed.

6.5 The main issue raised by respondents in this group, especially by manufacturers, was that they would not wish to see labelling arrangements in Scotland diverge from those in other parts of the UK. These respondents argued that this kind of divergence would be costly and wasteful and would make supply chains (needlessly) more complex. It would also bring competitive disadvantages due to the need for market-specific packaging which would be costly (as it would require smaller runs of packaging to be produced at higher unit cost and the productivity of production sites would be negatively impacted if lines had to be reset).

6.6 Other respondents from the food and drink industry commented on the difficulties which would be faced – particularly by smaller OOH operators and SMEs – if compulsory calorie labelling of menus (or any other measure requiring more detailed nutritional information on menus) was introduced. These smaller operators did not have access to nutritional expertise and would find it difficult to provide accurate information, especially given the frequency with which menus were changed.

6.7 It was not common for respondents from the food and drink industry to make suggestions for improvement. However, those who did offer suggestions generally echoed the points made by individuals and those in public health / third sector organisations. These suggestions were in the context of small improvements to a labelling system which they believed was generally performing well and should not be changed.

Views of individuals and those in public health / third sector organisations

6.8 Individual and public health / third sector organisational respondents were fairly positive about the current FoP traffic light labelling arrangements, but they also offered a range of suggestions for how the current system could be built on and improved, particularly in relation to its (i) voluntary status, (ii) coverage, (iii) standardisation, (iv) information coverage, and (v) textual and graphical presentation.

6.9 These respondents also expressed a range views about how the traffic light system is used. Moreover some respondents, particularly those in public health organisations and partnerships, also focused on the broader context, and particularly on questions relating to health inequalities.

6.10 Each of these points is expanded on below.

Voluntary status of FoP labelling

6.11 As set out in the consultation paper, the FoP labelling system is a UK-wide voluntary system. There was a widespread view among these respondents that FoP labelling should be made mandatory / compulsory. Occasionally respondents discussed this change as being brought about through a series of (small) incremental changes, but more often they simply expressed a view that ‘a mandatory system would be preferable’.

Coverage of FoP labelling

6.12 Respondents were aware that currently, FoP labelling was limited to pre-packed food and drink. They thought that the system should be extended to other types of foods (i.e. ready meals, all processed foods, freshly baked items, and products purchased online), and to the out of home sector (i.e. restaurants, takeaways, delicatessens, work canteens, etc.).

6.13 It was also suggested that alcoholic products and beverages should be covered by ( FoP) labelling. This was thought to be important because of the calories and sugar content in alcoholic products.

Standardisation and simplification of FoP labelling

6.14 Both individuals and public health / third sector organisational respondents commented that there were many versions of the ‘traffic light system’ in place. They thought this was confusing and that it would be preferable to have one standardised version which was adopted by everyone.

6.15 Requests for ‘standardisation’ often went hand-in-hand with requests to reduce ‘the complexity’, ‘the inconsistency’ or the ‘ambiguity’ of the current system. While it was recognised that some subtle distinctions would be lost in making this change, respondents overall felt that simplicity and comprehensibility of the system were crucial if the labelling was to be useful to – and more used by – consumers.

Labelling information

6.16 There was a very strong focus in the comments on the importance of providing information which related to (i) a realistic portion size and (ii) the actual pack being purchased (rather than some arbitrary reference amount). For example, in relation to the first point, one respondent noted that ‘the calories look OK until you realise the portion size is unrealistically small’.

6.17 Other items which respondents wished to feature – or to feature more prominently – in the FoP labelling scheme included: protein, ‘nutritional density’, vitamins and nutrients. It was suggested that in an ideal system a single number, or composite score should be produced for each product (the analogy of a unit of alcohol was offered).

6.18 There was a particular focus on how information about sugar and ‘hidden sugar’ should be presented. It was thought there was much room for improvement in this area. Suggestions included: (i) using teaspoons as well as grams; (ii) distinguishing naturally occurring from refined sugars / other sugars; and (iii) distinguishing sugars which are added (‘extrinsic’) from those which are naturally part of the raw product (‘intrinsic’).

(Textual and visual) presentation of labelling information

6.19 There was a strong focus in respondents’ comments on making sure that labelling information was clearly presented. Respondents said the information should not be ‘hidden’ or ‘concealed’ by making it very small print and / or placing it somewhere on the package where it was unlikely to be seen. It was also suggested that consideration should be given to the effectiveness of labelling for people with poor health literacy. This meant that the presentation would have to be clear, to incorporate images (including perhaps emojis), that it would have to be in a large font, and be written in plain English.

6.20 Participants in the Scottish Youth Parliament’s engagement exercise echoed these views. They thought that traffic light labelling was confusing and a few said that they had been completely unaware of these labels. This group thought the traffic light labelling should be better communicated and that it should be mandatory. They also wanted these labels to include another column which would indicate how much exercise would be required to work off the calories contained in the product (‘if a pizza box says it is 100 Kcal, it means nothing – but if it said how long it would take to burn off this type of food, this would make an impact’).

Using the traffic light system

6.21 While respondents were reasonably positive overall about the traffic light system, some individuals raised questions about its use. For example, they asked:

• How should two ‘amber’ ratings be combined?
• Did it make sense to award a ‘green’ to an item which had no nutritional value?
• What balance of ‘red’, ‘amber’ and ‘green’ would be required for a ‘healthy’ basket of food?

Broader context of health inequalities

6.22 There was a concern, particularly expressed by public health organisations and partnership groups, that focusing on labelling undermined the main message of the consultation paper. While (mandatory) labelling is regulated by government ( EU, UK) and voluntary codes of practice are administered or adopted on an industry-wide or business-specific basis, the impacts of labelling (and the response to the information contained in the labelling) depends on the individual. These respondents highlighted that it was therefore possible (and some cited evidence that it was likely) that improving labelling could increase inequalities (since it was likely that those in the least deprived groups would respond to a greater degree to the ‘messages’ contained in the labelling than those in the most deprived groups).

6.23 These respondents thought it was important to place a greater emphasis on addressing wider influences (education, support, training, tackling the obesogenic environment using upstream interventions, etc.) which had more impact on people’s food choices.

Other points

6.24 Other relevant issues raised by respondents were that labelling should be improved for specific groups (vegans, diabetics and children were specifically mentioned), and that new technologies should be exploited (including online calorie calculators and apps).